Custom Environmental Services Ltd.7722 - 9th Street

Edmonton, Alberta T6P 1L6

www.proeco.com

Telephone (780) 440-1825

Fax: (780) 440-2428Toll Free 1-800-661-5792

Mayor and CouncillorsCity Of EdmontonOffice of the Councillors2nd Floor, City Hall1 Sir Winston Churchill SquareEdmonton, AB T5J 2R7

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Friday, August 04, 2006

Dear Mayor and Councillors:

RE: Administrative InQuirv.Hazardous Waste Spill. Response To Questions Presented ToCouncil On Fridav Mav 26. 2006

c:'With respect to heading "D.1.aHazardous Waste Spill (D. Thiele)" there in fact was no spill of c.hazardous waste in this incident. There however was an emission of substance into the air that C)::0was caused by a pinhole leak in a drum of Class 8 Corrosive materials that reacted with the ~moisturein the air. :5(..J

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On May 23 2006 the chemical reaction did not force the evacuation of business. The evacuation '8'enwas called by the City Of Edmonton Fire Department, at their request, as a preventative measurefor public safety reasons.

Management at Custom Environmental Services Ltd. as a public safety measure called the EFDHazardous Materials Response Team. The company requested assistance to bring the emissionunder control and stop any further action as management of the company was concerned that afire might occur.

The May 5, 2005 fire started in mid afternoon Thursday and the site was returned to CustomEnvironmental Services Ltd. on Friday morning at approximately 10:30 in the morning. Allsurrounding businesses were back at work on Friday morning at 8:00 AM less than 24 hours afterthe incident started.

CouncilCorrespondence

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Points:

1. Custom Environmental Services Ltd. provides needed waste management services toIndustrial, Commercial and Institutional clients. Those clients include the City ofEdmonton Eco Stations, hospitals, paint shops, metal fabricators, chemicalmanufacturers, refineries, and a myriad of other clients that are located in the greaterEdmonton region. The types of hazardous waste and hazardous recyclable wastesthat are handled by the company are typical of the commercial chemicals used byother companies in the area. In most cases the waste materials are used or spent, offspecification commercial chemical products. We act as a focal point for collection ofthese materials to assist the waste generators in proper recycling and or disposal of thewaste. Many waste generators do not have the time, resources or knowledge requiredto address the all of the legal and other requirements to cost effectively managehazardous waste and hazardous recyclable waste. These generators of waste mustfind assistance to ensure that the waste they generate is disposed of or recycleddiligently.Custom Environmental Services Ltd. received a license from Alberta Environment,the now defunct Alberta Special Waste Management Corporation, and the EdmontonBoard of Health over the period from 1989through 1991. The company hasmaintained the license in good standing through at least 5 reapplications over theyears. The current approval is valid until 2009 at which time an application must befiled for renewal. Our goal has always been to diligently work with the regulators tomeet and exceed applicable regulations.Custom Environmental Services Ltd. emphasizes safe operations in compliance withall environment, heath and safety regulations. The company has provided the servicesand is currently working on project # 19,800 since acquiring an approval from AlbertaEnvironment in 1989. A project could be the collection of a 5 litre pail of waste or infact a truckload of 80 drums of waste. We strive to ensure that the generatoraccurately identifies the material we receive and we have a hierarchy of receivingrequirements to try to identify noncompliant packaging and materials that may bemislabeled or not identified properly. We make every effort to fix a problem onreceipt as the consequences are a safety concern to our staff and surroundingneighbors.Hydrazine is classified as a Class 8 chemical and because it is a caustic, it can be, andis stored in metal containers. Although a plastic container would be preferable,transferring the hydrazine in a moist environment would be contra-indicated due to itspropensity to become unstable when exposed to moist air. When material is placedinto the storage areas, it is in the appropriate containers. Material that is sent to anywaste management facility may be several years old and yet the container may appearto be brand new. Containers that develop pinholes, as was the case in this instance,cannot be foreseen and they must be dealt with when the condition is discovered.The hazardous Materials Response Team was called due to their training and thecapabilities that they provide to protect the general public and workers at industrialsites. Custom Environmental Services maintains a complete inventory of materialsthat enter its facility, that are managed in daily activities, the location of where

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materials are placed into storage and records of materials leaving the facility. Thisinventory is updated daily. The inventory is stored in hard copy at the facility,electronically at the facility with daily backup onsite and daily backup offsite at aremote location. The hydrazine drum in question was stored in a segregated storagefacility with compatible materials. Staff at Custom could not read the label on thedrum to identify the contents due to the emission that was happening. When we wereinformed of a specific air monitoring result from Alberta Environment we were able,within minutes, to ascertain which drum and the contents of that drum from ourinventory. We were fully aware of all of the materials stored in the segregatedcontainer at all times, however the actual drum was not verified until it was removedfrom the container. Our priority is to react positively and proactively to insure thesafety of our staff, our neighbors and the general public. In this particular case ourmanagement made a decision to call for assistance to achieve our priority.All materials of a hazardous nature shipped to our facility are identified by severalmethods. The use of a Hazardous Waste Manifest defines the waste name, class ofwaste, United Nations PIN Number, waste state (solid, liquid, gas, sludge)volume/mass of the described materials, consignor of the waste, transportationcompany, receiver of the waste. In addition the waste as received is visually checkedto insure that proper labels are located on the container. Each received container ofwaste is given an inventory bar code by Custom staff and entered into our inventorysystem with all the applicable Hazardous Waste Manifest information. When a dailytransaction such as repackaging, recycling, movement to a different facility location,shipment off-site, bulking, placement into a tank occurs that transaction is recorded inthe inventory system.Staff are trained under the Transportation of Dangerous Goods Act and Regulationsas well as WHMIS (although not required by law). The company maintains a trainingmatrix which tracks employee training, retraining requirements and certificates oftraining received. In addition the staff are required to read the company proceduresmanual and any updates and present signed verification that they have understood thecontents. The majority of material handled at the facility is flammable by nature andstaff are well aware of the proper handling procedures involved. For material that isnon-routine, staff are briefed on the appropriate handling procedures and all necessaryPersonal Protective Equipment (PPE) is available and used. A recent inspection byAlberta Human Resources and Employment found no significant issues withCustom's operations.The company's Alberta Environment approval does not allow the acceptance ofexplosive or radioactive waste material therefore no staff at Custom work withexplosives. Custom's staff wear all of the appropriate PPE at all times. In today'ssociety, the myriad of chemicals that can be considered carcinogenic is astounding.Would it be Council's recommendation that all citizens of Edmonton stop pumpinggas into their vehicles due to the high levels of benzene (a known carcinogen) in thegasoline? Safety assurances are derived from the proper use ofPPE in order tomitigate, to the greatest extent possible, the exposure to this myriad of chemicals,whilst continuing to provide valued services to our clients. We would like to representto Council that our existence is an integral part of the waste management process in

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Alberta. We have handled large volumes of wastes through our facility over the yearswith an extremely low instance of incidents of any kind.Incidents of this kind are minimal in frequency and duration. The last twooccurrences were coincidental with respect to the 16 years we have been at thislocation.Custom has given notice in a local paper whenever Alberta Environment requires alicense renewal. We maintain a list of adjoining neighbors and contact information ifwe in fact have to give notice of an incident. We have an open-door policy regardingour operations. We actively invite those interested to attend our site and view ourinnovative recycling operations and how we manage waste materials that areconsidered hazardous by their nature.The fire on May 5, 2005 (Thursday)was caused by a chemical reaction in an open topprocess bin that was being filled. Flaming materials blown out of the bin caused theresulting fire. The Alberta Environment air monitoring report on the incident isavailable on the Alberta Environment web site. The fire in the chemical storage areawas put out within 2 hours of the fire department attending the site. In the fall of2004 a new built up tar roof was placed onto the office/warehouse portion of thebuilding. When this started to bum the fire department could not get it under controland this caused major damage to the building and resulted in the fire continuing wellinto the evening. Custom provided a complete inventory of materials that were on thesite to Alberta Environment on the Tuesday after the fire. Seven days later weprovided an inventory of what was left in the affected areas and within 3 weeks of thefire we verified exact amounts and material types that were consumed in the fire. 29drums of waste materials were consumed in the tent area of the site. Approximately3,500 liters of hydrocarbon waste materials were destroyed in a tank. In retrospect thefire loss in additionto the lossof ~ 1 kilogramof hydrazinecomparedto the amountof materials handled at the facility in the last three year results in a loss ratio of .012%or 1110of 1 %.

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The company has had no third party safety requirements placed on it as a result of thefire. The company has implemented changes to its operating procedures to furtherreduce the risk associated with the type of operation that was taking place. Thecompany has also removed the waste generator in question from our acceptable clientlist as they have refused to make available their waste management plans andprocedures for identifying materials prior to shipment. The company has alsoreplaced the built up tar roof on the building with a steel roof as a risk managementtool. An engineered foam fire suppression system has been installed to discharge intothe area where the initial incident occurred as a risk management tool.

The company is not aware of any further investigation, enforcement or complianceissues related to the May 5, 2005 fire incident.

After the May23, 2006 Hydrazine incident the company has been inspected by AlbertaEnvironment and The City of Edmonton Fire Department. There have been several suggestions

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to improve the company's operations. We are currently reviewing the suggestions andimplementing changes to operations and facilities in discussion with the groups.

It should be noted that Custom Environmental has always encouraged and in some cases askedfor visits from regulatory and safety groups to review our operations and specifically have askedfor assistance in improving how we conduct those operations.

In closing we extend an invitation to any members of the City Council and the CommunityServices Committee to attend our facilities and see what we do to protect the environment andserve the citizens of Edmonton.

Sincerely yours,Custom Environ

Brian WintersPresident

CC: Office of the City Clerk3rdFloor City Hall1 Sir Winston Churchill SquareEdmonton, Alberta T5L 2R7

BW / 211-869/B

file City-O-CESL--Administrative-Inqui.doc

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2006CSF010 Attachment 1

D.l. ADMINISTRATIVE INQUIRIES

D.l.a. Hazardous Waste Spill (D. Thiele)

Councillor D. Thiele requested the permission of Council to make an AdministrativeInquiry.MOVED J. Batty- B. Anderson:

That Councillor D. Thiele be permitted to make an Administrative Inquiry.

CARRIED

ABSENT:

S. Mandel; B. Anderson, 1. Batty, T. Cavanagh,E. Gibbons, R. Hayter, 1. Melnychuk, M. Nickel,M. Phair, L. Sloan, D. Thiele.K. Krushell, K. Leibovici.

FOR THE MOTION:

Councillor K. Krushell entered the meeting.

"On May 23,2006, a chemical reaction at Custom Environmental Services(7722-9 St) forced the evacuation of several businesses in a block-and-a-half area in the Southeast Industrial Area.

The EMS Hazardous Material Response Team arrived to deal withunknown vapours corning from metal drums stored on the site in a tent.

Community Svcs.

CS Committee

Due: Aug. 21, 2006

On May 5, 2005, a major explosion and fire occurred at this same sitecausing an evacuation and shutdown of businesses in the area for one totwo days.

1. Is the type of hazardous waste management conducted by CustomEnvironmental Services appropriate for the Southeast Industrial area?

2. Is the hazardous waste management conducted there compliant withAlberta Environment standards and licensing?

3. What safety assurances do the owners and employeesof thesurrounding business have, given that they are working in very closeproximity to a hazardous waste facility that has had two seriousincidents that could have endangered human life injust over a year?

D.l.a. cont.

4. Reports indicated that hydrazine was at fault. Why was hydrazine,known to react with metal and wood, being stored in metal containerson a wooden pallet?

2006CSF010 Attachment 1

5. The Hazardous Materials Response Team and others were placed inconsiderable danger and lost essential time as they attempted todetermine what materials they were dealing with. Why was CustomEnvironmental Services unaware of what was in the barrels?

6. Are hazardous waste management companies required to be familiarwith what materials they are receiving and handling?

7. What training do employees of Custom Environmental Servicesreceive in dealing with hazardous waste?

8. What safety assurances do the employees of Custom EnvironmentalServices have given they are working with explosives, carcinogensand a myriad of hazardous materials?

9. Who will compensate the surrounding businesses for time and moneylost when they were forced to close down operations for lengthy timeperiods?

10. How are surrounding companies and neighbourhoodsnotified ofpotential dangers?

11. What were the results of the 2005 explosion? What caused thefire/explosion? What, if any, additional safety requirements wereplaced on the company at that time?

The report should return to Community Services Committee."

2006CSF010 Attachment 1